Compulsory retirement must rest on bona fide public-interest assessment, not disguised punishment or collateral motives.

Compulsory retirement under the applicable service rule is not a punishment, but it must be based on a bona fide assessment of the employee's entire service record and relevant material in public interest. Judicial review is limited, yet interference is justified where the order is mala fide, arbitrary, perverse, or unsupported by evidence. On the stated facts, the authority relied largely on the employee's criminal cases and efforts to secure their withdrawal, while the service record did not show adverse integrity entries and the review process was not consistent. The retirement order was therefore treated as punitive and collateral rather than a valid public-interest exercise, and the employee's challenge succeeded.

---

---

Issues: Whether the order of compulsory retirement was based on a bona fide assessment in public interest under the applicable service rule, or whether it was punitive and passed for a collateral purpose.

Analysis: Compulsory retirement under the relevant rule is not a punishment and may be ordered only when the authority forms a bona fide opinion, on the basis of the entire service record and relevant material, that retirement is required in public interest. Judicial scrutiny is limited, but interference is warranted where the order is mala fide, based on no evidence, arbitrary, or perverse. On the record, there were no adverse entries regarding integrity, the later character roll entries after promotion were unavailable, and the Review Committee itself did not consistently recommend compulsory retirement. The action ultimately taken was driven largely by the respondent's involvement in criminal cases and by an attempt to secure withdrawal of those cases, rather than by a proper assessment of overall service record or public interest.

Conclusion: The compulsory retirement order was not supported by adequate material and was treated as punitive and collateral rather than a valid exercise of power in public interest. The challenge succeeded in favour of the respondent.

Final Conclusion: The appeal failed, and the respondent's reinstatement stood confirmed.

Ratio Decidendi: An order of compulsory retirement must rest on a bona fide, evidence-based assessment of the employee's overall service record and public interest, and it is liable to be struck down if it is arbitrary, unsupported by material, or used as a disguised punishment.

---